Dive Brief:
- Ahead of the One Big Beautiful Bill Act’s July 4 deadline for wind and solar projects to commence construction in order to capitalize on the Inflation Reduction Act’s investment and production tax credits, developers have met the occasion and safe-harbored a massive pipeline of projects, industry experts say.
- Crux, which provides a marketplace for the transfer of tax credits, in February estimated a 170 GW pipeline of safe harbored projects. “So it's presumably only grown over the past seven months,” Josh Price, Crux’s director of intelligence and research, told Utility Dive.
- Price, along with Camelot Energy Group Head of Energy Storage and Emerging Markets Raafe Khan, predicted that as projects are no longer eligible to qualify for IRA tax credits, the price of power purchase agreements for those projects is likely to go up.
Dive Insight:
“If you don't have the ITC, you have to make that up with revenue and cost,” Khan told Utility Dive. “There's not so much that a developer can do on cost as much as they can do to negotiate a PPA rate that is favorable, but that does push forward-looking power pricing to the higher end.”
Khan said that Camelot Energy Group analyzed the difference between a tax-advantaged and a non-tax-advantaged solar asset, and found that the example case of a 200-MW solar facility with a 30% investment tax credit would need a PPA “in the $40 to $45 per megawatt hour range. But if you're non-tax advantaged, no ITC basis, then you're basically pushing mid-to-high $60s.”
“That's a 50% increase in power price alone, and that's going to put a lot of pressure on utilities and developers,” he said.
Price said that in the absence of tax credits, “that missing money has to come from somewhere to make the project pencil, and that will likely be through PPA prices, so really it's kind of a shift from the taxpayer to the ratepayer to make up that delta.”
In the meantime, however, Khan said “a healthy amount of projects” that are tax-advantaged will complete construction and be placed in service between 2028 and 2030. “I do think that solar still has a very bright future,” he said.
“We don't really see any kind of sharp drop-off coming up on Saturday, or really over the next four years,” Price said. “And one of the reasons is this has been projected or telegraphed to developers since at least the passage of [the OBBBA], so a year ago is when a lot of these decisions were made to safe harbor, to meet the construction deadlines.”
The One Big Beautiful Bill Act, which President Donald Trump signed into law July 4, 2025, stipulated that wind and solar projects had to commence construction within a year of the law’s enactment to qualify for the IRA’s clean electricity production and investment tax credits, or be subjected to an end of 2027 “placed in service” deadline to be eligible.
“If you miss the deadline coming up, it is highly unlikely or improbable that you will be able to get a project in the door and placed in service before December 31 [2027], unless you are just so far along from all the work you've done in years past that you are basically at the finish line in terms of interconnection, and that your equipment is in a warehouse just waiting to be delivered,” Khan said. “I think that is very much an outlier, I think that's more of the exception than the norm.”
Looking ahead
Chris Girouard, renewable energy tax credit attorney at Bryan Cave Leighton Paisner, said in an email that after July 4, he expects “energy industry participants to focus on their safe harbored projects through the end of the decade and lobby for changes in law that reintroduce tax credits applicable to wind and solar projects.”
“To the extent tax credits become available for wind and solar projects that began construction after July 4, 2026, we expect the development of those projects to quickly pick back up,” Girouard said. “Outside of the wind and solar context, we expect that the increased attention in other energy technologies will continue to grow. Specifically, we are already seeing increased interest in battery and nuclear projects.”
Bryen Alperin, managing director at Foss & Co, also said he anticipates solar and wind credits possibly being “extended sometime in the next few years.”
“There are plenty of safe harbored projects,” Alperin said in an email. “As we get to 2029 to 2030, we may have a shortage of solar and wind projects, but by then we expect to have ramped up volume in other technologies.”
Energy storage tax credits were left unscathed by the OBBBA’s cuts to the Inflation Reduction Act, offering batteries a boost, said Price and Khan.
“One thing that I feel confident in, is it’ll be a lot of storage,” Price said. “We've already seen a lot of storage deployment … Q1 was a record quarter.”
Khan said he thinks that industry thinking could even shift from solar-plus-storage to storage-plus-solar to power data centers, “to be able to provide a firm shape to the power output of the facility, so that it can actually match the utility’s load profile or the data center's load profile much better.”
Another challenge posed by the OBBBA was its new foreign entity of concern rules, which have complex provisions and have received limited additional guidance from the U.S. Department of the Treasury so far.
Khan said that although FEOC enforcement began at the start of this year, “the rules are still not clear, and everyone's obviously talking to law firms to try to get a better sense of the lay of the land, and we are dealing with an environment where it almost seems manufactured for confusion.”
Girouard said he found the guidance released in February, which offered interim safe harbor guidance for calculating a project or component’s material assistance cost ratio, was “helpful to address market concerns.”
“However, the lack of guidance regarding the effective control rules continues to be challenging for the renewable energy industry,” he said. “We, along with almost all of the industry, are hoping that forthcoming guidance from the IRS on those rules is released soon and that the guidance provides a practical approach to complying with the effective control regime.”